CASE DIGEST
ANTONINO v. BANCO DE ORO UNIVERSAL BANK, INC.
[G.R. No. 273446 and G.R. No. 273493, (2025)]
THIRD DIVISION, GAERLAN, J.
Banking Law; Time Deposit Certificates (TDCs); Possession of Original TDCs; Burden of Proof; Laches; Bank's Fiduciary Duty; Damages
The possession of the original Time
Deposit Certificates by the depositor is compelling evidence that the deposits
have not been redeemed where the certificates themselves require surrender upon
redemption. Banks, because of the fiduciary nature of their business, are held
to the highest degree of diligence in verifying withdrawals and preserving
records. Failure to observe such diligence renders the bank liable not only for
the unpaid deposits and accrued interest but also for damages. Banks may be
held liable for moral damages suffered by depositors due to negligence, even if
there is no proof of bad faith or malice.
Remedios and
Angelita Antonino made several US Dollar time deposit placements with Banco de
Oro (BDO) San Lorenzo Branch, evidenced by various Time Deposit Certificates
(TDCs). They claimed that the deposits were subject to an agreement for
automatic rollover if left unredeemed because they resided most of the time in
the United States.
Years later, after recovering the original TDCs from a safety deposit box kept in Banco Filipino, they demanded payment from BDO. The bank refused, claiming that the deposits had already been redeemed in 2001 and presented internal transaction records and a demand draft allegedly signed by Angelita as proof of withdrawal.
Angelita denied redeeming the deposits and presented a Bureau of Immigration certification and passport records showing that she was outside the Philippines on the date of the alleged withdrawal. A handwriting expert likewise testified that the signature on the demand draft was probably not hers.
The RTC and the Court of Appeals ruled in favor of Remedios and Angelita, ordering BDO to pay the proceeds of the time deposits covered by four TDCs. BDO elevated the matter to the Supreme Court.
1. Whether Remedios and Angelita
sufficiently proved their entitlement to payment of the deposits covered by TDC
Nos. 1117687, 1193123, 1193124, and 1193125 despite BDO’s claim that these had
already been redeemed.
YES. The evidence preponderantly established that the four TDCs had not yet been redeemed. The Supreme Court sustained the factual findings of the RTC and CA. It emphasized that possession of the original TDCs by Remedios and Angelita strongly indicated that the deposits had not been redeemed because the terms and conditions of the TDCs expressly required surrender of the certificates upon redemption. If redemption had truly occurred, the original certificates should have been in the possession of BDO.
The Court found BDO’s evidence less persuasive. Its computer-generated transaction histories were merely internal records. More importantly, the alleged redemption through Angelita was contradicted by official BOI records and passport entries showing that she was not in the Philippines on the date of the supposed withdrawal. The Court gave full evidentiary weight to the BOI Certification as a public document enjoying the presumption of regularity.
The handwriting
expert’s testimony further reinforced the conclusion that Angelita likely did
not sign the demand draft. Consequently, BDO failed to establish that the
deposits had already been paid.
2. Whether Remedios and Angelita were
barred by laches due to their long delay in claiming the deposits.
No. Remedios and
Angelita were not guilty of laches. The Court rejected BDO’s argument that the
claim was stale due to the passage of time. The TDCs contained a provision
stating that if not redeemed, renewed, or rolled over on maturity, they would
automatically earn interest as savings deposits. Moreover, BSP regulations
provide that matured time deposits not withdrawn or renewed shall be treated as
savings deposits earning interest until actual withdrawal or renewal.
Given these contractual and regulatory provisions, the deposits remained active and interest-bearing. There was therefore no abandonment, neglect, or unreasonable delay that could justify the application of laches. To rule otherwise would undermine the very nature of investment instruments intended to appreciate over time.
3. Whether BDO was liable for moral
damages, exemplary damages, attorney’s fees, and interest.
Yes. BDO was liable
for damages and attorney’s fees. The Court reiterated that banks are engaged in
a business impressed with public interest and are required to observe a degree
of diligence higher than that of a good father of a family. BDO failed to
exercise such diligence when it allegedly allowed redemption by a person whose
identity and authority were not properly verified, failed to require surrender
of the original TDCs, and could no longer produce critical documents supposedly
supporting the redemption.
The Court found that Remedios and Angelita suffered mental anguish and anxiety from being deprived of their investments. Accordingly, it awarded:
- USD 100,000.70 plus accrued interest on
the four valid TDCs;
- ₱100,000.00 moral damages;
- ₱300,000.00 exemplary damages;
- ₱150,000.00 attorney’s fees;
- Costs of suit; and
- 6% legal interest per annum on the total
judgment award from finality of judgment until full payment.
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